ASK MAT:- What factors should I consider in my Customer Risk Assessment (CRA) process to address FOREIGN BRIBERY RISK

ASK MAT:- What factors should I consider in my  Customer Risk Assessment (CRA) process to address FOREIGN BRIBERY RISK (PS I’m in Jersey)

MAT SAYS

• Thank you for clarifying your location – I'll offer some guidance to assist you with Jersey-regulated firms (under the JFSC) in updating their Customer Risk Assessment (CRA) procedures to address foreign bribery risks explicitly. 
• For those  in other locations, the core guidance below will also apply

MAT SAYS:-

1. MATS OVERVIEW

• Foreign bribery is a predicate offence for money laundering under the Proceeds of Crime (Jersey) Law 1999 (as amended). The Money Laundering (Jersey) Order 2008 and the JFSC AML/CFT Handbook require a risk-based approach to identify and mitigate bribery and corruption risks within the broader ML/TF/CPF framework.
• Incorporating the International Foreign Bribery Taskforce (IFBT) Indicators of Foreign Bribery ensures your CRA remains effective, proportionate and aligned with international best practice.
• The IFBT document (available at https://www.afp.gov.au/sites/default/files/2026-01/IFBT-Indicators.pdf) collates real-world indicators drawn from the collective experience of the Australian Federal Police, RCMP, New Zealand Police/Serious Fraud Office, UK SFO/NCA and US FBI.

2. Key Principles from the IFBT

• Indicators are not stand-alone. They must be assessed in combination and within context.
• No single indicator automatically equals criminality; however, multiple indicators or indicators combined with other risk factors (PEP status, high-risk country, complex structures) elevate the customer’s overall risk rating and may trigger Enhanced Due Diligence (EDD).
• Indicators apply to both individuals and corporate customers (including beneficial owners, controllers and third parties).

3. MATS Recommended Updates to the CRA Process

3.1 Add a Dedicated “Foreign Bribery Risk” Section to the CRA Questionnaire / Automated Tool

• Insert the following categories and indicators (verbatim or adapted) as a new CRA module.
• Against the categories and indicators (verbatim or adapted)

• Firms must assign an overall Foreign Bribery Risk Score for this section using the firm’s approved scoring protocols – for example, I use
• LOWEST – 1 • LOW – 2 • MEDIUM – 3 • HIGH – 4 • HIGHEST – WEIGHTED 5
• The HIGHEST score (5) is weighted in accordance with the firm’s existing CRA weighting methodology (e.g. multiplied by a pre-defined weighting factor or automatically escalates the customer to the highest overall risk band).
• The Foreign Bribery Risk Score feeds directly into the overall customer risk rating.

Risk categories and indicators (verbatim or adapted)

PEP ASSOCIATION AND CONDUCT

• Has links to a PEP linked to a foreign company
• Has links to a PEP who owns real estate in a foreign country
• Is a PEP, or has links to a PEP, associated with entities linked to high-risk industries
• Is a PEP, or has links to a PEP, whose wealth greatly exceeds their public service salary
• Has links to a PEP in a high-risk country that has school-aged children attending an offshore private school
• Has frequent unmonitored interactions with a PEP or PEPs
• Excessive gifts, travel or hospitality are given to a PEP
• A Politically Exposed Person (PEP) requests additional fees
• Employs or contracts PEPs in foreign countries of operation

Conduct

• Uses third-party agents or consultants
• Applies multiple aliases or record names inconsistently across datasets
• Utilises shell companies
• Provides or uses multiple email addresses across different domains
• Regularly creates new companies or businesses which are only registered, or registered in their name, for a short time
• Makes unexplained large payments to overseas third parties or consultants
• Makes payments to offshore accounts or shell companies
• Engages in transactions with vague or non-existent documentation
• Deals with inflated invoices or overpays for services
• Undertakes offshore cash transactions or is linked to requests for cash payments
• Business partners or agents refuse to provide details on transactions
• Is linked to requests to make payments through third parties or to unrelated accounts
• Requires unusual secrecy in relation to transactions or contracts and is reluctant to share financial records
• Requests a high level of discretion around a particular contract
• A third-party agent or consultant requests additional fees without explanation
• Foreign contracts are awarded without a competitive bidding process
• Contracts are awarded to a party that lacks the apparent capability
• Foreign agents or consultants are hired without proper due diligence

Government Affiliations

• Business involves foreign government contracts
• Requires foreign government permits, approvals or licences to undertake or operate a business
• Is involved in lobbying foreign governments for legislative change

Country Links (see Section 4 below for enhanced checks)

• Has links to a country with a Corruption Perceptions Index score <40
• Has links to a country with a Corporate Tax Haven Index score >70
• Has links to a country with a Financial Secrecy Index score >75
• Has links to a country with Citizenship or Visa by Investment provisions (Golden Passport / Golden Visa)
• Has three or more passports from multiple countries
• Incorporated in a country with no real connection to that country
• Operates in a net export country

Ownership

• Owns property through a trust
• Owns a business that doesn’t align with their occupation
• Owns multiple properties without a mortgage or with a shorter mortgage
• Owns, buys or stores high-value assets in a foreign country
• Owns cryptocurrency
• Has a high-value property portfolio disproportionate to income
• Has a high-value property portfolio disproportionate to company size
• Purchases assets from the government below market rate
• Has limited identifiable assets in their name; however, the immediate family has significant assets
• Owns real estate overseas
• Owns shares/companies through complex structures
• Is a shareholder in a company through layers of complex company ownership
• Owns property through trust(s) or transfers property through trust(s)
• Owns assets purchased from a foreign government
• Is a bespoke charity buying property

Registration Information

• Charity registered with the same name as the company
• Is on, or linked to, the debarment, banned list or sanctions list
• Changes between industries
• Is a shell company or uses shell companies
• Business description does not align with the officeholders’ occupation

Other Associations

• Has a criminal history or adverse reporting, including in relation to foreign bribery allegations
• Is associated with a profession known to facilitate crime
• Is linked to a person on a debarment list, a banned list or a sanctions list
• Is associated with multiple trusts
• Is associated with a bespoke / project-specific charity
• Has links to companies across multiple industries

3.2 Risk Scoring, Weighting & EDD Triggers (using firm’s scoring protocols)

Apply the following methodology to determine the Foreign Bribery Risk Score (1–5) for this dedicated section:

Notes to the above

The HIGHEST score is weighted (as defined in your firm’s CRA policy) when calculating the final customer risk rating. Record the exact score, the indicators relied upon, and the rationale for every assessment (audit-trail requirement).

WARNING NOTE: Simplified Due Diligence (SDD) Exceptions and Foreign Bribery Risk –

1. Important Regulatory Reminder for Jersey AML-Regulated Firms - Under Articles 16, 17 and 18 of the Money Laundering (Jersey) Order 2008, firms may apply Simplified Due Diligence (SDD) / CDD exceptions in certain prescribed low-risk situations. However, the following rules are mandatory:
2. A full Customer Risk Assessment (CRA), including the new dedicated Foreign Bribery Risk section and scoring (1–5), must always be completed — even when SDD is being considered.
3. SDD must not be applied if any foreign bribery indicators are present or if the Foreign Bribery Risk Score is Medium (3), High (4) or HIGHEST (5).
4. Where heightened foreign bribery risks exist (score 3 or above) or where any Article 15 trigger is identified, the firm must apply standard Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD) in accordance with its risk-based policies. SDD is prohibited in these circumstances.
5. The decision to apply (or not apply) SDD must be clearly documented, including the full rationale and how the Foreign Bribery Risk Score was taken into account.
6. Failure to conduct a proper risk assessment or to apply SDD correctly in the presence of foreign bribery indicators constitutes a regulatory breach. This requirement applies at onboarding and during all periodic reviews or trigger events. Reference: JFSC AML/CFT Handbook + Money Laundering (Jersey) Order 2008 (Articles 16–18). This Warning Note should be read in conjunction with the main CRA Foreign Bribery Guidance and the firm’s EDD Policy. Review annually or upon any legislative changes.

3.3 Integration Points

• Customer Onboarding – add the new section to digital/paper forms.
• Periodic Review / Trigger Events – re-assess whenever a customer link to a foreign government contract, PEP, or new country is identified.
• Transaction Monitoring – calibrate rules to flag the conduct indicators (e.g., unexplained payments to shell companies, inflated invoices).
• Business-Wide Risk Assessment (BWRA) – update the corruption/foreign-bribery sub-risk assessment.

4. Enhanced Country Risk Assessment (Mandatory)

In addition to existing FATF, sanctions and geographic risk ratings, explicitly evaluate the following using the latest published scores:

Sources to the above

• https://www.transparency.org/en/cpi/2024
• https://cthi.taxjustice.net/
• https://fsi.taxjustice.net/

Recommendation:

• Always cross-reference both the Financial Secrecy Index and the Corporate Tax Haven Index when assessing country links, as endorsed by the IFBT and Tax Justice Network.

5. Appendix 1 – Countries Offering Citizenship by Investment (CBI) or Residency by Investment (RBI) – 2026 Consolidated List

• Citizenship by Investment (Golden Passport) –
• Active Programs Antigua & Barbuda, Dominica, Grenada, St. Kitts & Nevis, St. Lucia, Vanuatu, Nauru, Sao Tome & Principe, Turkey (and 7 additional confirmed global programmes per 2026 mapping).
• Residency by Investment (Golden Visa) – Active Programs
• Portugal, Greece, Malta, Italy, Hungary, Cyprus, Latvia, Luxembourg, Bulgaria, UAE, Thailand, United States (EB-5).
• Sources for verification (use latest editions):
• goldenvisas.com, citizenx.com, openvisa.org, movingto.com, mygoldenvisa.io, globalcitizensolutions.com.

6. Implementation Steps

1. Update CRA policy, procedures and templates (within 3 months).
2. Train relevant staff (onboarding, relationship management, compliance) on the new indicators and the 1–5 scoring protocol (with HIGHEST weighted).
3. Update automated CRA systems/risk engines to incorporate the new scoring.
4. Test the revised CRA on a sample of existing high-risk customers.
5. Document the change in your annual MLRO report to the JFSC.

7. Glossary (extracted from IFBT)

• Politically Exposed Person (PEP) – includes government officials, military officers, judges and high-ranking executives of state-owned enterprises.
• Shell companies – legal entities with no active operations or significant assets.
• Complex company structures – multiple layers and jurisdictions that can obscure beneficial ownership.
• Net export country – maintains a trade surplus.

8. Reporting & Further Guidance

• If indicators suggest possible foreign bribery, report promptly to the relevant authority (Jersey Financial Crimes Unit / JFSC / police) and consider a Suspicious Activity Report (SAR).
• Further advice is available from the JFSC AML/CFT team or the IFBT member agencies listed in the original document.

Approval & Review:

• When you finalise, your own guidance should be approved by the BOARD and MLRO / Compliance Officer and reviewed annually or upon material changes to the IFBT Indicators or index methodologies.

Conclusion

• By embedding these IFBT indicators andyour firm’s scoring protocols (LOWEST-1 through HIGHEST-weighted 5) into your CRA, your firm will strengthen its defences against foreign bribery and associated money-laundering risks while meeting Jersey’s regulatory expectations.

SOURCES - In developing the above guide, the following indicators have been used

The IFBT’s Indicators of Foreign Bribery

• recommend using both the Financial Secrecy Index and the Corporate Tax Haven Index in evaluating country links. [ALSO ATTACHED] 
  • https://www.afp.gov.au/sites/default/files/2026-01/IFBT-Indicators.pdf

On page 2, the IFBT’s Indicators of Foreign Bribery Country links

• Has links to a country with a Corruption Perceptions Index score <40 >
  • https://www.transparency.org/en/cpi/2024
• Has links to a country with a Tax Haven Index>70 >
  • https://cthi.taxjustice.net/
• Has links to a country with a Financial secrecy index score >75 >
  • https://fsi.taxjustice.net/#scoring_id=268
• Has links to a country with CITIZENSHIP OR VISA BY INVESTMENT PROVISIONS (Golden  passport/Golden visa) >
  • See Appendix 1 below

APPENDIX 1

A COUNTRY WITH CITIZENSHIP OR VISA BY INVESTMENT PROVISIONS (GOLDEN  PASSPORT/GOLDEN VISA)

• There is a single consolidated list of all countries offering Citizenship by Investment (CBI) (Golden Passports) and Residency by Investment (RBI) (Golden Visas). Still, it is not maintained by any one government. Instead, up‑to‑date consolidated lists are published by specialist investment migration organisations.
• Below is a clean, unified list of all countries currently offering Citizenship by Investment (direct passport acquisition) and Golden Visas / Residency by Investment programs in 2026, based on the latest verified sources.

1. Countries Offering Citizenship by Investment(Golden Passport)

These are countries where you can obtain citizenship directly, typically within months, through donation, real estate, or approved investment.

Caribbean Region Country  Minimum Investment            Source

• Antigua & Barbuda   $230,000 donation/real estate         [goldenvisas.com]
• Dominica        $200,000 donation/real estate         [goldenvisas.com]
• Grenada         $235,000 donation/real estate         [goldenvisas.com]
• St. Kitts & Nevis        $250,000 donation/real estate         [goldenvisas.com]
• St. Lucia         $240,000 donation/real estate         [goldenvisas.com]

Pacific / Oceania - Country  Minimum Investment            Source

• Vanuatu          $130,000 donation    [goldenvisas.com]
• Nauru $105,000 donation    [goldenvisas.com]
• Sao Tome & Principe           $90,000 donation      [goldenvisas.com]

Other Regions Country        Minimum Investment            Source

• Turkey            $400,000 real estate  [goldenvisas.com]

CBI Programs Confirmed Active (Total: 16 Programs Globally)

• A recent mapping study confirms 16 active CBI programs worldwide. [citizenx.com]

2. Countries Offering Golden Visas/ Residency by Investment (RBI)

• These programs provide residency, often with a pathway to citizenship after several years.
• Below is the consolidated 2026 list of all active Golden Visa programs.

European Golden Visas (Schengen & non‑Schengen) Country Investment Requirement     Notes            Source

Portugal        

• €500,000 funds          Real estate route closed      [openvisa.org]

Greece           

• €400,000–€800,000 real estate         No stay requirement [openvisa.org]

Malta

• (MPRP)           €169,000+       Permanent residency           [movingto.com]

Italy    

• €250,000–€2M            Investor visa  [movingto.com]

Hungary        

• €250,000         Re launched program          [movingto.com]

Cyprus          

• €300,000 real estate  Residency only         [movingto.com]

Latvia

• €305,000         Investment + fee       [movingto.com]

Luxembourg 

• Investor residence                [mygoldenvisa.io]

Bulgaria        

• Investor residence                [mygoldenvisa.io]

Middle East / Asia Country  Investment Requirement     Source

UAE   

• AED 2M ($545k) real estate [openvisa.org]

Thailand (“Privilege Visa”) 

• $19,000 (5 year visa)[movingto.com]

Americas - Country  Investment Requirement     Source           

• United States (EB 5) - $800k–$1,050,000    - Green Card path     - [movingto.com]

Caribbean (Residency options separate from CBI)

• Many Caribbean states only offer CBI, not Golden Visas — but they are sometimes grouped in RBI lists.

Summary: “Single List” of All Countries Offering Investment Migration

Citizenship by Investment (Golden Passport) – 2026

• Antigua & Barbuda
  Dominica
  Grenada
  St. Kitts & Nevis
  St. Lucia
  Vanuatu
  Nauru
  Sao Tome & Principe
  Turkey
  (Confirmed 16 total global programs)
• [goldenvisas.com], [citizenx.com]

Residency by Investment (Golden Visa) – 2026

• Portugal
  Greece
  Malta
  Italy
  Hungary
  Cyprus
  Latvia
  Luxembourg
  Bulgaria
  UAE
  Thailand
  United States EB‑5
• [openvisa.org], [movingto.com], [mygoldenvisa.io]

Complete Source List  

Source

• https://tinyurl.com/4j4ev4f7
• https://taxjustice.net/press/fbi-and-five-eyes-law-enforcement-agencies-adopt-the-tax-justice-networks-financial-secrecy-index-and-corporate-tax-haven-index/?utm_source=newsletter&utm_medium=email&utm_campaign=danish_pm_staves_off_electoral_defeat_with_wealth_tax_pledge_as_millionaire_exodus_author_exposes_own_tracking_claims&utm_term=2026-04-01

A clean list of all sources used to compile the consolidated list of countries offering Citizenship by Investment (CBI) and Golden Visas/Residency by Investment (RBI).

• https://www.goldenvisas.com/countries-offering-citizenship-residency-by-investment-in-2026
• https://globalresidenceindex.com/citizenship-by-investment/
• https://bestcitizens.com/2026/03/25/best-citizenship-by-investment-countries-2026/
• https://getgoldenvisa.com/best-citizenship-by-investment-countries
• https://citizenx.com/insights/citizenship-investment-map
• https://wherecani.live/countries-offering-citizenship-by-investment/
• https://getwherenext.com/blog/golden-visa-countries-2026
• https://www.globalcitizensolutions.com/golden-visa/
• https://www.openvisa.org/blog/golden-visa-programs-2026-which-countries-still-offer-residency-by-investment
• https://immigrantinvest.com/golden-visa/
• https://movingto.com/b/golden-visa-countries
• https://mygoldenvisa.io/blog/schengen-golden-visa
• https://www.globalcitizensolutions.com/residency-by-investment/